OFAC Enforcement Actions in 2022
OFAC published 16 civil penalties and settlements in 2022, totaling $42.7 million, more than twice the 2021 total of $20.9 million (20 actions). The largest 2022 OFAC penalty was $24.3 million against Bittrex, Inc. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.
- Total penalties$42.7Mvs 2021: $20.9M
- Total actions16vs 2021: 20
- Largest penalty$24.3Mvs 2021: $8.6M
2022 OFAC Penalties
2022 OFAC Enforcement by the Numbers
OFAC resolved 14 of its 16 enforcement actions in 2022 through settlements. The median penalty was $381,599. Enforcement was concentrated in the second half of the year, with 7 actions in the first half and 9 in the second, including 5 in the third quarter.
Iran-related sanctions were cited in 8 of the 16 actions, Cuba in 7, Syria in 6, Russia in 4, and Sudan in 3. Banking accounted for 4 actions, and securities accounted for 3 actions. All 16 actions targeted companies.
By total penalties, 2022 ranks 11th of the 20 years in this database, and 17th by number of actions. For the 13 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $536 million; those parties ultimately paid $42.6 million, an aggregate 92% reduction.